Comment on CFPB-2012-0050-0001

With regard to the proposal to postpone the effective date of subpart B of Regulation E until 90 days after the current proposal to amend subpart B has been finalized, I offer the following in support: 1. The requirements of the regulation are, by dint of the requirements imposed by section 1073 of the Dodd-Frank Act, complex and present significant challenges to remittance transfer providers, including banks and credit unions. 2. There have already been four formal issuances on the road to the final rule -- the proposal by the Federal Reserve Board, the final rule by the CPFB in February 2012; the contemporaneous proposal by the CPFB concerning the "safe harbor" definition of "normal course of business"; the final rule in August 2012 on the "safe harbor" definition; and the instant proposal to provide some relief to remittance transfer providers relating to disclosures and to the error resolution provisions establishing liability standards for remittance transfer providers. These issuances suggest that the CFPB and the remittance transfer industry itself made false starts in the process of developing final rules, and that additional time should be provided before compliance with the rule is required for sufficient understanding of the complexities of the rule and for implementation of any procedural or systems modifications that will need to be completed by remittance transfer providers and/or their third-party service providers. 3. It makes little sense and can only contribute additional confusion to enforce the current February 7, 2013, effective date only to make significant changes to disclosure requirements and liability provisions within the next several months. Instead, confusion and costs involved in implementation can be minimized by postponing any mandatory effective date until the instant proposal is finalized. A new effective date that is 90 days after the final rule is released seems to be a fair compromise.